With the revamped Scheduling Letter, a construction contractor flagged for a review will have to produce detailed documentation at the outset of a compliance audit. (CWC had urged the agency to require only summary data from construction contractors at the beginning of a compliance evaluation and to request additional information only when and if there was reason to believe that violations were occurring.)
OFCCP is also requiring construction contractors to document their compliance with OFCCP regulations. Item 16 on the Itemized Listing requires them to report all selection procedures in their hiring process. Item 17 requires evidence that the contractor monitored its personnel practices to ensure that they did not have a discriminatory effect.
Furthermore, the proposed new Itemized Listing would require construction contractors to report employment activity for employees involved in on-site functions that are incidental to the actual construction.